Transfer Pricing Calculator
Arm's-length pricing analysis for intercompany transactions using OECD CUP, Cost Plus, and Resale Price methods with tax exposure estimation.
Inputs
Results
CUP Method Price
$95,000.00
≈ 9 years of state college
How to Use This Calculator
- Enter Actual Transaction Price ($), Cost Base ($), and Resale Price ($).
- Set Comparable Market Price ($), Cost Plus Markup (%), and Resale Gross Margin (%).
- Adjust Comparability Adjustment (%), Corporate Tax Rate (%) as needed.
- Review the CUP Method Price ($) result.
- Use Cost Plus Price ($) and Resale Price Method ($) to inform your decision.
How the result changes with Comparable Market Price ($)
| Comparable Market Price ($) | CUP Method Price |
|---|---|
| 100,000,000 | $100,000,000.00 |
| 350,000,000 | $350,000,000.00 |
| 650,000,000 | $650,000,000.00 |
| 900,000,000 | $900,000,000.00 |
What each input means
- Actual Transaction Price ($)
- The price actually charged in the intercompany transaction.
- Cost Base ($)
- Total cost incurred by the supplying entity (for Cost Plus method).
- Resale Price ($)
- Price at which the product is resold to an unrelated party.
- Comparable Market Price ($)
- Price observed in comparable uncontrolled transactions (CUP method).
- Cost Plus Markup (%)
- Standard arm's-length markup on cost (typically 15-40%).
- Resale Gross Margin (%)
- Gross margin earned by the reseller (typically 20-50%).
- Comparability Adjustment (%)
- Adjustment to CUP for differences in terms, volume, or geography.
- Corporate Tax Rate (%)
- Applicable corporate tax rate for exposure calculation.
What each result means
- CUP Method Price
- Arm's-length price via Comparable Uncontrolled Price method.
- Cost Plus Price
- Arm's-length price via Cost Plus method.
- Resale Price Method
- Arm's-length price via Resale Price method.
- Arm's-Length Range Low
- Lower bound of the interquartile range.
- Arm's-Length Range High
- Upper bound of the interquartile range.
- Arm's-Length Median
- Average of the three method prices.
- Deviation from Median (%)
- How far the actual price deviates from the median.
- Within Arm's-Length Range
- 1 = within range (compliant), 0 = outside range (risk).
- Potential Tax Exposure
- Estimated additional tax if authorities adjust to median.
- Effective Markup on Cost (%)
- Actual markup achieved on the cost base.
How this is calculated
Worked example, using the default values
- Identify Input Parameters4 parametersActual Transaction Price ($) = 100000, Cost Base ($) = 60000, Resale Price ($) = 120000, Comparable Market Price ($) = 95000 = 8 input(s) provided
- Calculate CUP Method PriceCUP Method Price = comparableMarketPrice * (1 + priceAdjustmentPct / 100)95000 = $95,000
- Calculate Cost Plus PriceCost Plus Price = costBase * (1 + costPlusMarkupPct / 100)75000 = $75,000
- Calculate Resale Price MethodResale Price Method = resalePrice * (1 - resaleGrossMarginPct / 100)84000 = $84,000
Engine last updated .
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